Tax residency in UK

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All income. The company is considered tax resident in that country because of management.‍

Not where the manager is resident but where he is⁣ taking decisions.

Look i understand what you are trying to achieve and the only way⁢ to make it work is to make the LLC tax resident in a tax free︀ jurisdiction or a low tax jurisdiction.
 
Understood. I just wanted to make sure that it doesn't matter how other countries treat‌ US LLC - as a transparent or opaque entity. It looks like US LLC should‍ always pay CIT in any country where a manager is taking decisions even though US⁠ LLC is teated as a transparent entity in that country.
 
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